Legal Opinion
Rod Warren Ink, a Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 20, 1990No. 89-70328PublishedCited by 4 opinions
1Opinion of the Court
GEORGE, District Judge:
I. BACKGROUND
In this action, Rod Warren Ink (Ink) appeals from an adverse decision by the United States Tax Court. Rod Warren Ink v. Commissioner, 92 T.C. 995 (1989). The sole issue before this court is whether theft losses are deductible only in the year of discovery pursuant to section 165(e) 1 for purposes of calculating the personal holding company (PHC) tax imposed by section 541 et seq. 2 According to section 165(e), “any loss arising from theft shall be treated as sustained during the taxable year in which the taxpayer discovers such loss.” The tax court held…
2Cases cited6 opinions
- Watt v. AlaskaSupreme Court of the United States · 1981
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Jacob Abdalla and Mary T. Abdalla v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Knight Newspapers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Klamath-Lake Pharmaceutical Association v. Klamath Medical Service BureauCourt of Appeals for the Ninth Circuit · 1983
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Thornock v. JensenCourt of Appeals of Utah · 1997
- White's Ferry v. CommissionerUnited States Tax Court · 1993
- William H. Geisler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
- Willoughby v. CommissionerUnited States Tax Court · 1994